Immediate Civil Monetary Penalty Upon Immediate Jeopardy Citing

On July 22, 2016, the Centers for Medicare & Medicaid Services (CMS) released a revised S&C memo, Mandatory Immediate Imposition of Federal Remedies and Assessment Factors Used to Determine the Seriousness of Deficiencies for Nursing Homes (S&C: 16-31-NH), found here. The intent of this revision is to no longer allow states to not impose a remedy, rather the CMS Regional Office must immediately impose, without permitting a facility an opportunity to correct deficiencies, one or more federal remedies based on the seriousness of the deficiencies or when actual harm or Substandard Quality of Care is identified.

This impacts all surveys that happen on or after September 1, 2016.

Our clinical team, RMS is available to assist in conducting a mock survey and reviewing quality measures to identify potential areas at risk. For more information, contact an AssuredPartners NL Senior Living Agent.